United States
Environmental Protection
Agency
Municipal Environmental Research
Laboratory
Cincinnati OH 45268
Research and Development
EPA-600/S2-81-239 Jan. 1982
Project Summary
Guide for Spill Prevention
Control and Countermeasure
Inspectors
Walter Unterberg and Robert M. Moorehead
This report is intended for use in
training and guiding inspectors
performing compliance inspections
and amendment inspections and in
documenting these inspections to
implement the Oil Pollution Preven-
tion Regulations promulgated in
40CFR112 for nontransportation-
related onshore and offshore facilities.
The report covers the Spill
Prevention Control and Counter-
measure (SPCC) regulations, the role
of the SPCC inspector, the affected
facilities, and procedures for carrying
out the inspection. It contains forms
for use by the inspector in the field and
for documentation.
The use of these forms will provide
nationwide uniformity in SPCC
reporting. Suggested procedures
appear below in short form, applicable
to all inspections:
The SPCC Inspector's 1-2-3
1. In field, fill out "SPCC Inspection
Field Sheet" (1 page) (EPA Form
7500-53)
2. If facility in compliance
Fill out "APCC Inspection Sum-
mary Sheet" (1 page) only (EPA
For 7500-52)
// facility NOT in compliance
Fill out "SPCC Inspection
Summary Sheet" (1 page) (EPA
Form 7500-52) and "Detailed
SPCC Documentation" (7
pages) (EPA Form 7500-54)
,3. Enter information in EPA-SPCC
Data Bank;
Form A - Facility Indentification
Form E - Inspection/Enforce-
ment Report
Form S - Spill Report (if required)
This Project Summary was devel-
oped by EPA 's Municipal Environmen-
tal Research Laboratory, Cincinnati.
OH, to announce key findings of the
research project that is fully docu-
mented in a separate report of the
same title (see Project Report order-
ing information at back).
Introduction
In December 1973, the U.S.
Environmental Protection Agency (EPA)
issued in the Federal Register its Oil
Pollution Prevention Regulations for
Nontransportation-Related Onshore
and Offshore Facilities (40CFR112). The
purpose of these regulations is to
prevent spills from nontransportation-
related facilities by establishing
procedures, methods, and equipment
requirements for owners or operators of
facilities engaged in drilling, producing,
gathering, storing, processing, refining,
transferring, distributing, or consuming
oil. These regulations require the
owners or operators of designated
onshore and offshore facilities to
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prepare a Spill Prevention Control and
Countermeasure Plan (SPCC Plan) in
accordance with certain guidelines
contained within the regulations. These
guidelines require the installation or
construction of certain spill prevention
systems depending upon the type of
operation conducted at the facility. The
intention of these regulations is that
these spill prevention systems be
designed, installed, and operated
according to good engineering
practices.
Associated with 40CFR112 are sev-
eral other environmental regulations:
• 40CFR109, Criteria for State,
Local, and Regional Oil Removal
Contingency Plans — governing
contingency plans that are part of
SPCC plans under certain circum-
stances when conventional spill
prevention is not feasible;
• 40CFR110, Discharge of Oil —
applying 'to the discharge of oil
into navigable waters, adjoining
shorelilnes, or waters of the con-
tiguous zone;
• 40CFR114, Civil Penalties for Vio-
lation of Oil Pollution/Prevention
Regulations — outlining enforce-
ment procedures, with maximum
liability of $5000 for each day a
violation continues.
The SPCC inspection program is the
mechanism that the EPA uses to
determine compliance with SPCC
regulations. Compliance inspections
enforce 40CFR112.3 by verifying that
an SPCC plan exists for a facility falling
under 40CFR112, that this plan is
technically adequate, and that the
provisions of the SPCC plan have
actually been carried out in the facility.
The legal basis for compliance
inspections is contained in
40CFR112.3(b), which states, in part:
"Owners or operators of a
facility for which an SPCC plan
is required ... shall maintain a
complete copy of the plan . . .
and shall make such plan
available to the Regional
Administrator for on-site
review during normal working
hours."
When a spill of a certain magnitude
has occurred from a facility having an
SPCC plan, 40CFR112.4 requires the
owner or operator to submit his SPCC
plan to the EPA Regional Administrator
for review and possible amendment.
The Regional Administrator may require
that the plan be amended to minimize
the possibilities of spill recurrence.
After EPA review of the plan, an
amendment inspection may be
performed; this may result in additional
SPCC requirements being specified by
the EPA. The legal basis for this is
contained in 40CFR112.4(d), which
states, in part:
"After review of the SPCC
plan ... submitted by the owner
or operator . . . the Regional
Administrator may require the
owner or operator.. .to amend
the SPCC Plan if he finds that
the Plan does not meet the
requirements of this part or
that the amendment of the plan
is necessary to prevent and to
contain discharges of oil from
such a facility . . . and shall
specify the terms of such
amendment."
EPA's SPCC regulations were to be
implemented by 11 January 1975 by
about 30,000 oil marketing terminals
and bulk plants; about 285 oil refineries;
several thousand production facilities,
both onshore and offshore; and many
bulk oil consumers. As of June 1976,
the EPA had completed 12,313
compliance inspections. Evaluation of
the SPCC program to date, in terms of
spill histories and enforcement, has
disclosed variations among the EPA
regions.
Objective
Uniformity in carrying out SPCC
inspections is desirable, and therefore,
a document that provides uniform
guidance on a nationwide basis is
required. Also, personnel new to the
SPCC program need to be trained in
inspection and documentation
procedures.
This "Guide for Spill Prevention
Control Countermeasure Inspectors" is
to be a training and guidance report for
those performing compliance
inspections and amendment
inspections and for documenting such
inspections to enforce the Oil Pollution
Prevention Regulations promulgated in
40CFR112 for nontransportation-
related onshore and offshore facilities.
Operators/owners of such facilities
should also find this report useful in
developing their SPCC plans.
Contents
This report is divided into sections.
Section 1 is the introduction. Section 2
describes the role of the SPCC inspec-
tor, including the knowledge and skills
he should possess, the attitude and
behavior he should exhibit when deal-
ing with facility personnel, and the attire
and equipment he should take into the
field. Section 3 briefly covers the af-
fected nontransportation-related facili-
ties and their potential for incurring oil
spills. Section 4 is devoted to compliance
inspections — starting with prepara-
tions for the inspection, then cpntinuing
with the initial contact with the facility
and the SPCC plan review, and ending
with the facility inspection itself. Sec-
tion 5 deals with amendment inspec-
tions and parallels 4 in its sections. Sec-
tion 6 deals with documentation of
inspections. This is followed by a sec-
tion on references.
The appendices include texts of the
applicable federal EPA SPCC regula-
tions (Appendix A), a discussion of
nontransportation-related facilities
(Appendix B), an SPCC inspection check- .
list (Appendix C), Report of SPCC In- \
spection forms (Appendix D), and EPA-
SPCC Data Bank forms (Appendix E).
The report concludes with a Glossary of
the most commonly used terms.
The report is in looseleaf form so that
future additions, deletions, and correc-
tions can easily be made. Also, it per-
mits the report holder to insert other
pages as desired.
The full report was submitted in par-
tial fulfillment of Contract No. 68-03-
2648 by Rockwell International, New-
buryPark, California, under the sponsor-
ship of the U.S. Environmental
Protection Agency.
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W. Unterberg and R. M. Moorehead are with Rockwell International, Environ-
mental Monitoring & Services Center, Newbury Park, CA 91320.
John S. Farlow is the EPA Project Officer (see below).
The complete report, entitled "Guide for Spill Prevention Control and Counter-
measure Inspectors," (Order No. PB 82-115 296; Cost: $12.00, subject to
change) will be available only from:
National Technical Information Service
5285 Port Royal Road
Springfield, VA 22161
Telephone: 703-487-4650
The EPA Project Officer can be contacted at:
Oil and Hazardous Materials Spills Branch
Municipal Environmental Research Laboratory—Cincinnati
U.S. Environmental Protection Agency
Edison, NJ 08837
U S GOVERNMENT PRINTING OFFICE, 1982 —559-017/7437
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United States
Environmental Protection
Agency
Center for Environmental Research
Information
Cincinnati OH 45268
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